The Life Before This (1999) [Sheena]: Shot in the back (off-camera) in the crossfire of a shoot-out between David Hewlett and Joel Keller in a cafe. Her body is shown lying on the floor afterwards. (After this opening scene, the movie "rewinds" to the start of the day, leading up to an alternate outcome; in the second version, Catherine decides not to go into the cafe, and thus survives.) (Thanks to Tatan)